Human Tissue Authority

The regulator for human tissue and organs

Guidance on contingency storage arrangements for the deceased

The HTA licensing standards on premises, facilities and equipment aim to ensure that there are appropriate facilities for the storage of bodies and human tissue.

PFE2(b): There is sufficient capacity for storage of bodies, organs, and tissue samples, which takes into account predicted peaks of activity.

PFE2(c): Storage for long-term storage of bodies and bariatric bodies is sufficient to meet needs.

PFE2(i): There are documented contingency plans in place should there be a power failure or insufficient numbers of refrigerated storage spaces during peak periods

Guidance from Standard PFE2(i) states ‘Practices such as placing more than one body on a tray or storing bodies in unrefrigerated storage should not take place.’


Every year, death rates are higher in winter than other seasons in England and Wales. Winter is defined by the Office of National Statistics (ONS) to last between 1 December to 31 March. In recent years, the number of excess winter deaths has increased since 2014.

HTA-licensed establishments in the Post Mortem sector should have documented contingency plans in place to prepare for winter pressures. Your plans should clearly define the actions to take if your mortuary body store is nearing capacity or unexpected major equipment failure occurs. Storage for bariatric and long term freezer storage arrangements should also be considered as part of your planning.

Contingency arrangements should ensure the condition, dignity, security, and traceability of the deceased is always maintained. You should undertake a regular review of fridge and freezer storage capacity to ensure that it is sufficient and that anticipated shortages are captured in corporate risk registers.  There may be cases where capital expenditure may be required to increase capacity, and this should be highlighted sooner rather than later. You should also consider local authority cold weather plans in your planning and when developing your contingency arrangements.

HTA recommendations:

  • Make sure there is sufficient fridge and freezer storage capacity (including for bariatric bodies) available for local needs. They should consider peaks of activity and seasonal pressures. You should review capacity regularly and consider adding capacity shortages to your organisational risk register to identify where capital expenditure is required to mitigate risks to service delivery.
     
  • Contingency arrangements and mass fatality planning should be clearly separated. If you require an emergency mortuary licence, review your licence application regularly to make sure information is up-to-date and still applies. For example, that your Designated Individual is still suitable.
     
  • Be aware of key contacts within your Local Resilience Forum and maintain regular communication with them about your capacity and contingency arrangements.
     
  • Test out your contingency arrangements to make sure they are fit for purpose. Contingency arrangements should be shared across your region to understand interdependencies and overlaps with other organisations. You should also make sure that there are no conflicting demands on the same resources.
     
  • Consider a Mutual Aid Agreement with organisations close by so you can provide and obtain support during periods of capacity shortages. Where partner organisations are also experiencing capacity issues, you should have alternative options for increasing storage capacity.
     
  • Put in place traceability systems that track bodies coming into and out of the mortuary. You should risk assess and develop documented procedures that cover the transfer of bodies to contingency storage arrangements. This will mitigate the risk of an incident taking place. Risk assessments should consider the risk of a Post Mortem HTA Reportable Incident (HTARI) happening.
     
  • All temporary storage facilities should have temperature monitoring systems. They should be in a suitable and secure place to safeguard the security and dignity of the deceased. You should test alarm systems regularly, including callout systems.  You should put in place a numbering system for temporary racking to guarantee the position of the deceased is easy to establish.
     
  • Hiring temporary units or transferring bodies to funeral director premises should not be the only contingency arrangement. Make sure other formal arrangements are agreed and documented. You should review in advance how funding for these arrangements will be achieved and protected.
     
  • Put in place procedures to promptly follow up on delays in bodies being released due to lack of information given or third parties failing to collect bodies. Communicate regularly with local authorities to arrange publicly funded funerals in a timely manner.
     
  • Make sure that documented procedures for staff to follow are robust. They should reflect any alternative storage arrangements of bodies, including for out-of-hours arrangements to prevent inappropriate storage of the deceased. You should record the number of times alternative arrangements are used to inform regular review of the suitability of storage capacity.

You should not rely on just one contingency storage arrangement - please consider an escalating model. You should test and review all contingency storage arrangements regularly to make sure they are fit for purpose.

Audience: 
Sector: 
Last updated on: 23 Oct 2020